Re: civil penalty for medical violation

[William V Lipton <liptonw@dteenergy.com>]

My apologies for misinterpreting your e-mail, and that of others, as implying
support for noncompliance.

You asked whether the rulemaking process is being used.

The nuclear industry has several such ongoing or completed projects.  Some that
come to mind are:

(1) regulatory relief for mixed waste - The notice of proposed rulemaking was out
for comment earlier this year.  I posted this on RADSAFE.

(2) changes to the 10CFR50.59 "safety evaluation" process for power reactors,

(3) changes to emergency planning regulations in which the required emergency
exercise frequency has been reduced to every second year from every year,

(4) a revised NRC oversight program for power reactors, in which the safety
significance of an infraction must be considered in the enforcement determination
(BTW - a willful violation is considered to be highly significant.),

(5) a recent change to 10CFR20 which allows power reactors to burn contaminated
oil on site.

The process isn't perfect, but it can be used effectively.  I have trouble being
sympathetic with those who complain about regulations, but probably did not
participate in the rulemaking.

The opinions expressed are strictly mine.
It's not about dose, it's about trust.

Bill Lipton
liptonw@dteenergy.com

OFFTOWY@aol.com wrote:

...

>  Has anyone ever considered approaching the regulatory agencies with a request
> for rulemaking
> to roll back some of the more onerous requirements?  Has anyone done a
> relatively well justified cost/benefit analysis to identify the requirements
> that seem to have no significant basis?  If we are going to live with ALARA
> as a regulatory requirement, why not make the regs pass muster under that
> same requirement.  (Of course, ALARA might be the first one to go.)  If it is
> not worth doing, let's go to the rulemakers and get rid of it.
>
> The process does exist - are they open to this sort of thing?  Is this a good
> role for one of our societies?  The rules would seem to lie at the heart of
> promoting safety.
>
> Lew LaGarde
> offtowy@aol.com
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